CMS Releases Home Health Prospective Payment System Final Rule for CY 2013

Friday, November 02, 2012

CMS Releases Home Health Prospective Payment System Final Rule for CY 2013

On November 2, the Centers for
Medicare and Medicaid Services (CMS) released the final rule for the Home Health Prospective Payment System (HH PPS) for Calendar
Year (CY) 2013. The rule finalizes a reduction in rates of 1.32%, which is
approximately a $10 million decrease to payments for the home health 60-day
episode for CY 2013.

Of specific importance to
physical therapy, CMS finalizes 3 revisions regarding the requirement that a
qualified therapist complete a functional reassessment of the patient at the 14th
and the 20th visit, and every 30 days. First, CMS finalized its
proposal that if a qualified therapist missed a reassessment visit, therapy
coverage would resume with the visit during which the qualified therapist
completed the late reassessment, not the visit after the therapist completed
the late reassessment. Second, CMS finalized its proposal that in cases where
multiple therapy disciplines are involved, if the required reassessment visit
was missed for any one of the therapy disciplines for which therapy services
were being provided, therapy coverage would cease only for that particular
therapy discipline.

Third, CMS clarifies that in
cases where the patient is receiving more than one type of therapy, qualified
therapists must complete their reassessment visits during the 11th, 12th, or
13th visit for the required 13th visit reassessment and the 17th, 18th, or 19th
visit for the required 19th visit reassessment. However, CMS also states in
instances where patients receive more than one type of therapy, if the
frequency of a particular discipline, as ordered by a physician, does not make
it feasible for the reassessment to occur during the specified timeframes
without providing an extra unnecessary visit or delaying a visit, then it will
still be acceptable for the qualified therapist from each discipline to provide
all of the therapy and functionally reassess the patient during the visit
associated with that discipline that is scheduled to occur closest to the 14th
Medicare-covered therapy visit, but no later than the 13th Medicare-covered
therapy visit. Likewise, a qualified therapist from each discipline must
provide all of the therapy and functionally reassess the patient during the
visit associated with that discipline that is scheduled to occur closest to the
20th Medicare-covered therapy visit, but no later than the 19th
Medicare-covered therapy visit. The final rule reflects APTA's comments
urging CMS to maintain the current "close to" language.

In addition to the revision to
the therapy functional reassessment requirements, CMS also finalizes its
proposal to allow a nonphysician practitioner in an acute or post-acute
facility to perform the face-to-face encounter in collaboration with or under
the supervision of the physician who has privileges and cared for the patient
in the acute or post-acute facility, and allow such physician to inform the
certifying physician of the patient's homebound status and need for skilled
services.

Lastly,
the rule includes extensive provisions regarding the Home Health Conditions of
Participation and provides several avenues for home health agencies to meet the
survey and certification requirements and lays out CMS' remedial actions if
violations are found when surveys are conducted.

The
final rule will be published in the Federal
Register on November 8, 2012. APTA will post a summary of the final rule
shortly.

Comments

Thank you
Helpful information.

Posted by Tiffaney
on 11/2/2012 7:07 PM

Are you out of your mind? A $1200 combined cap? For a year? For the population that needs therapy the most? Outrageous. You're pushing good clinicians out of the country. I'll be following soon. Absolutely a disgrace

Posted by Joanna
on 11/2/2012 7:14 PM

private practices of any size may become a thing of the past. The proposed cap and the additional pending reductions will make it almost impossible to provide quality care. It will take time for the public to realize and react and by that time it will be too late.

Posted by don
on 11/3/2012 7:39 AM

a class action law suit for patients was filed against the federal government for not paying for therapy services. The judge ruled in favor of patients and part of the ruling said that physical therapy services were to be provided by federal government for all clients whether they improved or not and across skilled, homehealth, outpt. Obama administration agreed to fund it and comply with law suit. It was in the new york times paper a week ago Monday. It said all therapy claims denied prior to 2011 were to be paid. The suit was filed in Vermont.

Posted by christy race
on 11/9/2012 11:50 PM

Where can I find the HH PPS 2013 Final Rule? Your link above (where you click on final) http://www.ofr.gov/%28X%281%29S%28hkmwqmnmrsebmaruddiiy2k3%29%29/OFRUpload/OFRData/2012-26904_PI.pdf
doesn't work.

Posted by Stacy Coleman
on 11/26/2012 5:29 PM

This is a great summary of the findings - Thanks! ACHC also did a nice Podcast about it.
http://achc.wordpress.com/2012/11/28/survey-the-expert-podcast-episode-3/